ML20062B210
| ML20062B210 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 10/13/1978 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | James E WISCONSIN PUBLIC SERVICE CORP. |
| References | |
| NUDOCS 7810230357 | |
| Download: ML20062B210 (1) | |
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UNITED STATES Jg NUCLEAR REGUc.t TORY COMMISSION 3 p,,l 'M ) j i
REGION ill i,;.(?(-/
e 799 noos v.tr noAo at.~.cuvu.itt,~o s so,22 OCT 13 78 Docket No. 50-305 Wisconsin Public Service Corporation ATTN:
Mr. E. W. James Senior Vice President Power Ge.neration and Engineering P. O. Box 1200 Green Bay, WI 54305, Gentlemen:
The enclosed II Circular No. 78-17 is forwarded to you for infor-mation.
If there ere any questions related to your understanding of the suggested actions, please contact this office.
Sincerely,
} 5 YA James G. Keppler Director
Enclosures:
1.
IE Circular No. 78-17 2.
List of IE Circulars Issued in 1978 cc w/encls:
Mr. C. Lucca, Plant Superintendent Central Files Director, NRR/DPM Director, NRR/ DOR
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEME'IT REGION III October 13, 1978 IE Circular No. 78-17 i
INADEQUATE GUARD TRAINING / QUALIFICATION AND FAL"SIFIED TRAINING RECORDS Description of Circumstances Recent physical protection inspections and investigations of allegations pertaining' to guard training hcve disclosed evidence of improper guard training practices and possible falsification of training records.*
These items were disclosed through:
(1) a review of existing guard training records; (2) interviews with guards and guard force supervisors which were conducted to detemine the accuracy of specific infomation contained on records, and; (3) unannouncec' cbservation of training activities.
In a number of situations, combinations of the above listed efforts were require'd to thoroughly identify the magnitude of the problems.
The circumstances described below illustrate that individuals, who are perfoming duties as guards / watchmen, may not be adequately
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trained under existing requirements and/or that documentation may not give a true description of actual guard training nor individuals' abilities to perfom job-related duties.
Examples of Qualification Records Falsification At one facility, a " record of certification" indicated that a guard had achieved a specific, passing score on a written test.
An examination of the actual test showed that:
(1) the test had never been fully completed by the individual, and (2) those portions of the test which had been completed were not corrected nor graded.
d Interviews with guards were conducted, at one location, to detemine if they had, in fact, received required training, even though records of that training were not imediately available.
The guards initially indicated that they had received the training.
Later, however, they confimed that their supervisors had instructed them to verbally verify the trair.ing regardless of actual training received.
- The regulatory bases for providing adequate training to guards /watcheen and for adequately documenting tHat training are included in Title 10, Code of Federal Regulations, Part 73 (10 CFR 73.55(b)(4)).
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1 IE Circular No. 78-17 October 13, 1973
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Examples of Weapons Qualifications Improprieties In another instance, " certification" of firearms qualification was provided in the fom of targets containing holes which were purported to have been made by guards during range firing.
It was later determined that the holes had ceen made with a pencil..In another case, a number of notarized firearms qualification forms were later discovered to contain information which did not accurately reflect facts.
At other locations, records provided'as evidence of training appeared adequate.
They contained infomation which indicated that individuals had qualified in the use of fireams with specific range scores.
Further investigation showed that the scores had been achieved by someone other than the individual who was certified.
In fact, other guards and guard supervisors or range instructors had fired the qualifying scores, but certified that the person, whose name appeared on,the record, had qualified.
When discovered, these. individuals were required to return to the range in order to adequately qualify.
The results of this second qualification attempt showed that some individuals could not qualify, even after exten-sive range practice and training.
They were subsequently not allowed to perfom duties as guards.
In another instance, persons who were not able to achieve a qualifying score from a required uistance were allowed to reduce that distance and Then fire for qualification.
Minimum qualifying scores were required to be obtained frem a distance of 25 yards, howeve*, they were actually obtained from less than 10 yards.
Also, an unannounced visit to a range by a management representative revealed that individuals were being allowed to use " bench rests" and supports when they could not qualify without them.
This practice was not included in the qualification procedure and is not an acceptable method i
for establishing firearms qualification.
Discussien Guards and watchmen, who are responsible for the protection of Nuclear Power Plants must successfully ccmplete a program of training and quali-ficaticn prior to assignment of sacurity duties.
Each guard or watchman, whether licensee employees or provided by contract must be tested and later requalified to ensure that they are capable of meeting and main-taining minimum levels of performance.
(10 CFR 73.55 and effective October 23, 1978 Appendix B to 10 CFR Part 73)
IE Circular No. 78-17 October 13, 1978 Accurate records of training and qualificatio'n scores are'necessary in order to provide management a means for determining whether or not an individual is able to initially meet and thereafter maintain performance levels.*
The previously listed examples demonstrated that the potential for a significant reduction in the effectiveness of the security organizati:n may exist and, further, that responsible management personnel may not te aware of this reduction.
This lack of awareness could compound the severity and duration of the vulnerability.
Management audits of guard training have been found, in some cases, to be either non-existent or severely deficient.
In some cases audits of of training prograns and practices have never been the actual quality'er cases the audits consisted of a spot review cf conducted.
In oth lesson plans and individual guard's training records with no attempt being made to verify the accuracy of those records.
Subsequently, in the cases cited, records were verified as false and confirmation was c'
obtained that training had not been given or was improperly administered.
Licensee management should monitor this training program so that incen-sistencies in the record that suggest either a lack of, or inadequate training can be detected, irrespective of whether these inconsistences are inadvertent or deliberate.
It should be noted that, in limited instances where a licensee conducted a comprehensive audit of records and actual training, management did identify significant problems and examples of apparent falsification.
In those cases, the disclosures enabled management to take adequate, decisive action to correct the identified problers.
Recommended Action c~
The purpose of this circular is to inform all licensees; (1) of situations that t, ave been found; (2) that their program to preclude similar situaciens will be evaluated by NRR during licensing review of their Guard Qualification and Training Plan submitted in accordance with Appendix B to Part 73, and; (3) to alert them that I&E inspectors will be assessing their situation. Therefore all licensees who are required to provide physical protection for Nuclear Power Plants in accordance with the provisicns cf the Code of Federal Regulations, Title 10, Part 73.55 should verify thac guards, watchmen or armed response individuals (as applicable) have been j
properly trained and qualified and huve adequately demonstrated capability l
to perform assigned duties.
Among the courses of action that the licensee could take are:
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- See A,merican National Standards Institute, " ANSI N18.171g73, Industria1 Security for Nuclear Power Plants," Section 4.9 " Audits and Reports.,
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IE Circular No. 78-17 October 13, 1978 A.
Review training records, certifications' and supporting documentation to verify that the records are accurate and complete t
and that they adequately reflect the demonstrated abilities of individuals currently performing dutics as guards, watchmen or armed response personnel.
B.
Interview or test guards, watchmen and response individuals in order to confirm that the specific information contained in records is accurate.
C.
Observe pertinent aspects of the training program to verify that the actual training being given is adequate.
This should include, but not be limited to:
classroom presentations, administratien of tests and range training and qualification.
This direct observation should include both initial training / qualification and retraining /
requalification activities.
No written response to this circular is required.
If you desire additional information regarding this matter, contact the Director of the appropriate r
NRC Regional Office.
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IE Circular No. 78-17 October 13, 1978 LISTING OF IE CIRCL1ARS ISSUE 3 IN 1978 Circular Subject Date Issued To
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No.
of Issue 78-01 Loss of Well Logging 4/5/78 All Holders of Source Well Logging Source Licenses 78-02 Proper Lubricating 011 4/20/78 All Holders of for Terry Turbines Reactor OLs or cps 78-03 Packaging Greater Than 5/12/78 All Holders of Type A Quantities of Reactor Ols, cps, Low Specific Activity Fuel Cycle, Radioactive Material Priority I Material for Transport and Waste Disposal I
Licenses 78-04 Insta11stien Error That 5/15/78 All Holders of Could Prevent Closing of Reacter OLs or Fire Doors cps 78-05 Inadvertent Safety Injection 5/23/78 All Holders of During Cooldown Reactor OLS cr cps 78-06 Potential Co==cn Mode 5/23/78 All Holders of Flooding of ECCS Equipment Reacter OLs or Roc =s at BWR Facilities cps
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78-07 Da= aged Co=ponents of a 5/31/78 All Holders of Bergen-Patersen Series Reactor OLs or l
25000 Hydraulic Test cps Stand 78-08 Environnental Qualificatien 5/31/78 All Holders of of Safety Related Equip =ent Reacter OLs er at Nuclear Pcwer Plants cps 78-09 Arcing of General Electric 6/5/78 All Holders of l
Company Size 2 Contactors cps Enclosure Page 1 of 2 s y
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II Circular No. 78-17 October 13, 1978
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,e LISTING OF II CIRCULARS ISSUED IN 1978 i
Circular Scbject Data of Issued to No.
Issue en 78-10 Control of Sealed 6/14/78 All Medical Sources Used in Licensees in Radiation Therapy Cate iries e and uA 78-11 Recirculation M-G 6/15/78 All!!'idersof Set Overspeed Stops BWR OLs or C?s 78-12 HPCI Tur'bine Control 6/30/78 All Holders of Valve Lif t Rod Bending BWR OLs or C?s for plants with HPCI Terry Turbine 78-13 Inoperability of Multiple 7/10/78 All Holders of Service Vater Punps Reactor OLs and C?s except for plants located in: AL, AK, CA, FL, GA, LA, MS, SC 78-14 HPCI Turbine Reversing 7/12/78 All Holders of 3WK Chanber Hold Down Bolting OLs or cps fer plants with a H?CI Terry Turbine excepting Duane Arnold and Monticello f
75-15 Checkvalves Fail to 7/20/78 All Holders cf Close In Vertical Reactor OLs or C?s Position 75-16 L1:1 torque valve 7/26/73 All Holders of Actuators Reactor OLs er C?s Enclesure Page 2 of 2
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